Object

Representation ID: 67220

Received: 27/06/2014

Respondent: Bloor Homes Midlands

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The draft Local Plan has failed to demonstrate:
* it has proactively driven/supported sustainable economic development, and done everything it can to support sustainable economic growth;
* it meets the business needs of the area and delivers homes to support the growth of the local economy;
* it is based on the most up-to-date and robust evidence about the economic prospects and needs of the area; and,
* it integrates the strategic policies for prosperity (Strategic Policies DS1 and DS8) and housing (Strategic Policies DS2 and DS6).
The level of economic growth to be provided for is not defined within the draft Local Plan.
The strategy for prosperity in the draft Local Plan is to provide for the growth of the local and sub-regional economy by ensuring sufficient/appropriate employment land is available to meet the existing/future needs of businesses (Strategic Policy DS1).
Policy DS8 provides for a minimum of 66ha of employment land to meet local need (for the period 2011 to 2030). The strategy for housing is to provide in full the objectively assessed need (Strategic Policy DS2). Policies DS6, DS7 and DS10 provides for 12,860 new homes (for the period 2011 to 2029).
The evidence base fails to support Paragraph 2.7 of the LP that economic growth has been balanced with housing growth, and that meeting the full objectively assessed need for housing will complement and meet the economic and business needs and ambitions of the District.
The evidence can be found within the Economic and Demographic Forecasts Study (EDFS) (December 2012), the Employment Land Review Update (ELR) (May 2013), and its economic ambitions can be found within the Strategic Economic Plan for Coventry & Warwickshire LEP (SEP) (March 2014).
The economic strength of Warwick is undeniable, and is summarised in paragraphs 3.1 to 3.6 of the ELR. Its economy has outperformed the West Midlands and UK in terms of its
growth and is forecast to continue that trend (both in terms of GVA and employment) into the plan period. Warwick has an economic structure which is aligned to the future growth sectors, such as professional services, healthcare, and IT.
Warwick also has a particular strength in the automotive/vehicle manufacturing sector, with several major employers including Jaguar Land Rover (JLR) who have facilities located both within and on the edge of the District. Given the significance of JLR to the national
economy, it is no surprise that the Vision for Coventry & Warwickshire in 2025 within the SEP is to be recognised as a global hub and a UK Centre of Excellence in the advanced
manufacturing and engineering sector. Many of the SEP's priorities and actions are focussed around facilitating the growth of this sector, including investment to deliver new/expanded facilities at several employment sites within and bordering Warwick District. The SEP has estimated its actions alone may generate over 50,000 jobs by 2030 across the subregion.
It is very clear from the evidence that the Warwick economy is undoubtedly the 'powerhouse' within the sub-region and West Midlands region. Its future economic performance and continued success is therefore critical to the overall performance of the sub-region and regional economy, and the delivery of the ambitions within SEP.
Whilst the availability of suitable employment land is a key factor influencing Warwick's future economic growth and prosperity, it is not the only component that the Local Plan will need to influence.
A key challenges is to ensure that the planned growth of Warwick and the sub-region's economy is not frustrated by lack of access to skilled workforce. To deliver a global hub and national centre of excellence, requires businesses to be able to attract the necessary talent. Providing access to available homes of a high quality is an essential
component of the offer. SEP recognises that the shortage of new homes can be a significant barrier to sustainable economic growth.
In this context, it is of concern that the objectively assessed housing need figure chosen by the Council fails to support a growth in labour supply that meets the forecasts for employment growth. The chosen housing figure only supports labour supply growth of 8,996 for the period 2011 to 2031 leaving a shortfall against the forecast of between 1,304 and 1,904 jobs.
This shortfall is likely to be under-estimated as the employment forecasts preceded the publication of the SEP and have not taken account of its potential influence in
accelerating the rate of growth of growing sectors within Warwick. Mindful of the growth in housing supply not keeping pace with the economic ambitions for the area, it is noted that the SEP prioritises a review of additional future housing numbers across the sub-region by the end of March 2015 (page 8). The draft Local Plan does state that it has taken account of the SEP, although there is no reference to a review of its housing numbers within the draft Local Plan.
Whilst it is recognised that the shortfall in labour supply growth might be mitigated through people holding down more than one job, or increased in-commuting from outside of the
District (as suggested within paragraph 7.28 of the SHMA), it is noted that when recommending the chosen housing figure, the SHMA advised the Council to consider its
alignment with forecast economic growth, and how employment growth will be supported.
It is not clear whether the Council has undertaken this exercise as the draft Local Plan does not explain how the shortfall between growth in labour supply and growth in jobs will be addressed, or what the implications may be. In commuting from outside the District is one possible consequence.
In this context, it is considered that the strategy has not been positively prepared as it has not proactively driven and supported sustainable economic development, or done everything it can to support sustainable economic growth. It does not meet the objectively assessed development requirements as set out in the evidence base, and therefore is not in accordance with the Framework.
The Council should therefore review its objectively assessed housing need figure prior to submission.
In the context of delivering sustainable development, this review should consider economic, social and environmental effects of increasing the level of housing growth in order to balance with the forecast economic growth and economic ambitions of the Council. Other representations made by Bloor Homes Limited to the draft Local Plan have identified locations where additional housing growth can be accommodated.
In the absence of this exercise being undertaken, Bloor Homes Limited would invite the Inspector to find this Plan 'unsound'.